Author Privacy Statement

This privacy statement addresses the personally identifiable information (“data”) that we (“us” or
“Neticle”)
collect
and process about individual authors of online content (“Author”, “you” or “your”) through the services that
we
offer
to our customers. Everyone who publishes information on publicly available websites is considered as an
author
for
purposes of this privacy statement.

General information

The information that we have access to is publicly available on the internet and it is published
or made
available by
Authors. We use crawlers to index and collect publicly available information (including data)
from the Internet
and we
also have contracts with third party providers to gain access to their information (including
data). We collect
and
store this information in our databases.

As an Author, you are the source of the data. You have control over that data within the
platform where you
publish it
on, just like the privacy settings and options made available to you by that platform or
website. In addition to
whatever
rights you have via your relationship with any publishing platform, you also have certain rights
relating to
your data that
we process, as set out in this Privacy Statement.

All of the information that we have access to is publicly available, the raw information we have
about you could
be found
by anybody online. Some of this information is personal data, like your name or username used on
social media
profiles. Other
information we process may not be personal data (for example if you leave an anonymous comment
under an article
or blog post).

We offer analytics of the collected data (our “Services”) to third parties and sometimes access
to the raw data
that is
relevant to our customers. A data is deemed relevant if it contains references to that
customer’s brand, product
or other
recognizable intellectual property.

What do we collect?

The collected data depends on what the source of the data (platform, website) makes available
for us and your
privacy
settings adjustments on them. This data could include the following:

your name, username or other identifier;

the content you have published under that name, username or other identifier, for example
comments,
expressions, opinions or posts etc.

a link to the origin of the data (for example a link pointing to your tweet)

any other information you publish on any Internet website we crawl on or a third party
platform that
provides us with data.

Sometimes we might deduce other information from the data connected to you. For example, we may
guess your
gender based on your name.

We may also analyse the content of the data published by you and provide this analysis to our
customers as our
Services. For example,
if you publish a Facebook comment stating that you don’t like a certain brand’s product, we may
mark that
comment as having a negative
sentiment in connection with that brand.

How do we use your data?

Neticle’s legitimate interest is providing such technology and analysis to the customers that
helps them
understand the online
contents written about their product or brand, so they can act in certain ways and make business
decisions with
more certainty.
Thanks to our Services, they can learn more about their brand, customers, competitors and other
information
available on the
Internet and is relevant to them. The legal basis for the data we process is in accordance with
our legitimate
interests.

Deducing data about you takes place automatically. Our algorithm based system analyses the date
published by
you, we don’t
make any decisions about the processing. The inferences are based on algorithms that analyse the
data that you
have posted.
It is up to our customers what (if anything) to do with that information.

We may also use the data to improve our Services.

Neticle’s main goal is to provide useful information from the collected data to our customers
though our
analysis.

Sharing your data

In addition to sharing your data with our customers, we may share your data with any member of
our company group
(i.e. our
subsidiaries, parent companies, and affiliates).

We may share your data with selected third parties, including our business partners, suppliers,
and
sub-contractors, for
the performance of any contract we enter into with them.

We may disclose your data to other third parties. For example, if we sell or buy any business or
assets, we may
disclose
your data to the prospective seller or buyer of such business or assets. Alternatively, if we or
substantially
all of our
assets are acquired by a third party, your data may be part of the transferred assets.

If any third party processes any of your data, we ensure there are sufficient contractual and
operational
safeguards
protecting your data.

Accuracy and retention

Most of the data we have about you comes directly from you. If it is inaccurate, we advise you
to fix it on the
original
platform in which you published that data. Where we deduce data about you, it is our aim to
ensure that any of
this additional
data is accurate and kept up to date.

We will retain any data about you for as long as it is reasonably necessary for us to provide
our Services.
However,
if you request to delete your data, or if you delete your data from the platform in which it was
originally
published,
we will also delete your data from our Services.

Storage, security and your rights

We may transfer your data to (and store it in) a country other than your own. That country may
not provide the
same
level of data protection as your own country.

The servers in which we hold your data have appropriate administrative, technical, and physical
controls that
are designed
to safeguard your data, including industry-standard encryption technology.

You have many legal rights in your data under applicable data privacy law. Under applicable law
you may:

request access to the data that we have about you and request it to be updated, rectified,
deleted, or
blocked

request that we refrain from further use of any data we hold about you.

To exercise any rights listed above, please email us at [email protected]
or write to us at the address listed at the top of this document.

Privacy practices of third parties

This privacy statement only addresses our collection, processing, and use (including disclosure)
of your data.
Our customers
and other third parties that may have access to your data can use it in other ways in accordance
with their own
privacy practices
and applicable law. We encourage you to familiarize yourself with the privacy statements
provided by any
platform you use to
publish any information.

Data processing and data protection regarding contacting users

The section of this privacy statement addresses the owner of personal data (“user”) that was
submitted through
any platform that
belongs to Neticle (“we” or “us”). Neticle stores the personal data of certain users for the
purpose of direct
marketing.
We only use these data if the user provided their data voluntarily and willingly. This
processing protocol is in
accordance
with the European Union’s General Data Protection Regulation (GDPR).

Newsletter

When signing up for a newsletter, these things fall under personal data:

name

email address

Neticle uses the MailerLite newsletter system, that additionally stores the user’s IP
address, time of signing
up, and
the website’s link that redirected the user to the sign up page.

If the user wishes to unsubscribe from our newsletter, this option is offered at the footer
of every email.

Social Media Sites

If the user subscribes through a direct marketing service, through a post on a social media
platform (Facebook,
LinkedIn),
the user gives consent to Neticle to store and use the user’s certain personal data, and to
send promotional
emails until
the user’s unsubscription.

The following falls under personal data:

name

email address

Furthermore, we store the following information that does not fall under personal data:

position at work

company name

place of residence (country)

Hubspot

In certain cases we input the personal data of potential clients onto the Hubspot system, so
we can send
promotional
emails to the user. This happens if the user provided their personal data when applying for
the trial version of
Neticle
(demo request). In certain cases, Neticle employees might send emails to the user even of
the user did not
request the
demo version of Neticle, but their email address is publically available to everyone on a
platform, where in all
likeliness
the user shared their personal data in order to facilitate contact.

In this case, the following falls under personal data:

name

phone number

email address

If a contract is signed between the user and Neticle afterwards, the contract will include
the contact person's
personal
data (name, email address, phone number). Neticle will continue to use this data for
promotional purposes, with
the consent
of the contact person.

We only use data for our own promotional purposes, we do not share it with third parties. The
servers where we
store
the data, are up to date and properly regulated administratively, physically and technically,
and were designed
to
guard and protect data, including the industry-standard encryption technologies. If the data is
stored on other
platform’s
server which we use for direct marketing, keeping your data safe and protected is their
responsibility.